ML20148S527

Safety Evaluation Supporting Amend 24 to License DPR-54 Concluding That Proposed Changes in Plant Org Are Admin in Nature & Preserve Intent of Tech Specs.Mods to Security & Emergency Plans Are Also Acceptable

ML20148S527
Person / Time
Site:	Rancho Seco
Issue date:	11/14/1978
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148S465	List: ML20148S471 ML20148S527
References
NUDOCS 7812010358
Download: ML20148S527 (4)

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4 UNITED STATES

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j NUCLEAR REGULATORY COMMISSION 3* WASHINGTON, D. C. 20655 s  !

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION I 1

SUPPORTING AMENDMENT NO. 24 TO FACILITY OPERATING LICENSE NO. DPR-54 SACRAMENTO MUNICIPAL UTILITY DISTRICT l l

RANCHO SECO NUCLEAR GENERATING STATION '

DOCKET NO. 50-312 Introduction By letter dated February 21, 1978, the Sacramento Municipal Utility District (the licensee) requested changes to the Technical Specifications appended to Facility Operating License No. DPR-54 for the Rancho Seco Nuclear Gener-ating Station (the facility). The proposed amendment would change the Administrative Controls portion of Appendices A and B of the license to reflect a revised plant organizational structure, and clarify the review requirements for changes to the Security and Emergency Plans and their implementing procedures.

Background

The present plant organizational structure is that given in the facility Final Safety Analysis Report. As such, it reflects the licensee's estimate of facility organizational needs made at a time prior to reactor operation.

Based on operating experience gained since that time, the licensee observed the need for changes in the plant organization in order to optimize opera-tions. The licensee states that the present request reflects these observed needs. In addition to requesting a change in the plant organization Ls set forth in the Technical Specifications, the licensee has proposed miscellaneous changes in the wording of the Technical Specifications to reflect the proposed revised organization, and to clarify the review requirements for changes to the Security and Emergency Plans and their implementing procedures.

Evaluation The principal effect of the proposed revised organization is to relieve the Plant Superintendent of responsibilities which are not directly concerned with plant operations. For example, in the present organization, the Plant Superintendent is not only responsibile for plant operation, but also 7812010356

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-2 supervises the technical support function and an administrative staff.

Under the proposed revised organization, all of these responsibilities are assigned to the Manager of Nuclear Operations, who exercises these responsibilities through subordinates. One of these subordinates is the Plant Superintendent, who supervises all operations, maintenance, and chemical and radiation personnel. Other subordinates to the Manager of Nuclear Operations are the Engineering and Quality Control Supervisor, the Administrative Staff and a Technical Assistant. The overall effect of the proposed change is therefore, primarily administrative.

One aspect of the proposed change which appeared to have possible significance i with respect to safety was the inclusion of quality control personnel in the plant organization. The basis for possible significance would be a possible i lack of independence between quality assurance functions and plant operations.

This matter was discussed with the licensee who stated that the quality control personnel shown on the proposed plant organization are the inspec-tors who assure that quality control requirements are met at the plant site. We also note that the quality assurance personnel report to the Engineering and Quality Control Supervisor, who is independent of the Plant Superintendent, thereby maintaining independence between quality assurance and operations. In addition, we note that the off-site organiza- .

tion is unaffected, so that the Quality Assurance Director still reports I directly to the Assistant General Manager, Chief Engineer ard is a regular ,

member of the Management Safety Review Committee. .Accordingly, based on l the foregoing, we conclude that the inclusion of quality control personnel  ;

in the plant organization as proposed by the licensee, does not reduce the independence needed by such personnel to effectively perform their duties and is therefore acceptable.

As noted above, the licensee has proposed certain changes in the Appendices A and B Technical Specifications to reflect the proposed revised organi-zation. We have reviewed these proposed changes and conclude that they are administrative in nature, that they preserve the intent of the Technical Specifications with respect to the organizational structure and are there-fore acceptable, ,

1 In this submittal, the licensee also proposed changes in the definition of '

responsibilities of the Plant Review Committee with respect to the review ,

of security and emergency plans and procedures (Sections 6.5.1.6.h and i).

We have reviewed these proposed changes and discussed with the licensee the reasons for proposing the changes. Based on these discussions, we have determined that the licensee's principal concern relates to the need for routine submission to the Chairman, Management Safety Review Committee, of

1 minor changes in Security implementing procedures which do not affect the facility Security Plan. The licensee states that such implementing procedures are opercting details and, as such, if the changed procedure maintains conformance with the provisions of the Securit,y Plan, the Manage-ment Safety Review Committee should not be required to perform a supervisory review of these details. The licensee further states that in order to protect the details of the security procedures, the review of changes to the procedures should be limited to that necessary to determine their acceptability and conformance with the Security Plan. The licensee adds, however, that if a proposed change in the implementing procedures was found to be not in conformance with the facility Security Plan, such that a change in the Plan would be required to permit implementation of the procedure, the proposed change in the Plan would be submitted to the Chairman, Management Safety Review Committee.

We are presently reviesing the licensee's Modified Amended Security Plan, submitted by letter dated October 14, 1977, and amendments thereto. On the basis of our review of this document, we conclude that the assignment of responsibility to the Plant Review Committee to determine the accept-ability of changes in implementing procedures for the Security Plan without further review is acceptabla. We also agree that dissemination of proposed changes to detaileo security procedures should be limited to the extent practicable. Accordingly, we have modified Technical Specification 6.5.1.6.h to clarify that only recommended changes to the Security Plan (and not changes in implementing procedures) need be submitted to the Chairman, Management Safety Review Committee. This modification of the licensee's original request has been discussed with and agreed to by the licensee.

In summary, we have reviewed the proposed. revised plant organization for the Rancho Seco facility and conclude that it is acceptable. We have also reviewed the proposed changes in the wording of the Appendices A and B Technical Specifications to reflect the proposed revised orgnization and conclude that these changes are also acceptable. Finally, we have reviewed the licensee's request with respect to the review of changes to the Security and Emergency Plans and their implementing procedures and have made modifications to the Technical Specifications which are acceptable to the NRC staff and have been agreed to by the licensee.

Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is not significant from the standpoint of environmental impact and, pursuant to 10 CFR 651.5(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.

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Conclusion We have concluded, based on the considerations discussed above, that:

(1) because the amendment does not involve an increase in the probability or consequences of accidents previously considered and does not involve e decrease in a safety margin, the amendment does not involve a signifcant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance

.with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

l Dated: November 14, 1978 l

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